All GP practices in England must be registered with the CQC by 1 April 2013 and complying with some of its essential standards and outcomes is challenging for some practices.
Judging from inquiries the MDU has received from its GP members, there are several misconceptions about what practices need to do to successfully register and about the CQC’s powers.
Here are main myths that practices can discount.
MYTH 1: Each practice in our group has to register for the CQC separately.
It is not necessary to submit separate applications for each practice within a group. A GP partnership with three practices only needs to complete a single application that includes details for each practice location.
When registering, you first need to decide what category of provider you fall into.
The categories are: individual (single-handed GPs); partnership (shared liability partnerships); or organisation (registered companies, other corporate bodies, charities, social enterprises, limited liability partnerships and complex partnerships, for example, company joint ventures).
When completing your application you need to declare each independently managed location where regulated activities are provided.
Practices with branch surgeries that treat patients from the same registered list do not need to declare these separately, but branch surgeries that treat patients from a different registered patient list need to be listed as separate locations.
MYTH 2: All the GPs at our practice need to obtain another CRB check to register.
The CQC has said that GPs with a GMC number will not have to obtain an enhanced Criminal Records Bureau (CRB) certificate.
However, if the person who will be the individual provider/partner or registered manager on your application is not a practising doctor, he or she will need to have applied for an enhanced CQC-countersigned CRB certificate before the application can be submitted.
Those who need a CRB certificate for CQC registration can apply online. The CQC will ask for their CRB application number on the registration application.
MYTH 3: CQC inspectors are going to spend hours checking practice policies and procedures.
Inspectors have been told to spend most of their time speaking to patients, their families and carers rather than looking at policies and procedures.
They will generally only want to see the latter to substantiate other evidence or confirm what they have been told.
The CQC has said it does not want its regime to generate swathes of red tape for GP practices.
For example, practices that gather evidence for the QOF, PCT contract monitoring or as part of schemes such as the RCGP Practice Accreditation scheme, will probably be able to reuse this to demonstrate compliance with the essential standards.
MYTH 4: We will need to inform the CQC every time we launch a new service.
You do not need to update the CQC about services it does not regulate, such as the provision of non-surgical cosmetic treatments (for example, ‘subcutaneous injections to enhance appearance and removal of hair or minor skin blemishes by application of heat using an electric current’).
However failure to register for all the regulated activities you undertake could leave you vulnerable to prosecution or even to a GMC fitness to practise investigation.
You must inform the CQC if you want to make changes to the regulated activities you provide, for example, providing a new service such as a slimming clinic or family planning service.
Information about the activities regulated by the CQC is available in its Scope of Registration document on its website.
It is a good idea to have a system in place to ensure the CQC is updated every time a practice partner joins or leaves; you open a new location; your registered manager changes and so on.
From early 2013, you will be able to make changes to your registration online at the CQC website.
MYTH 5: The CQC will make us remove the toys and magazines in our waiting room.
An essential CQC outcome for practices is ensuring that patients are ‘cared for in a clean environment and protected from the risk of infection’ (Outcome 8: Cleanliness and infection control).
With magazines, for example, the CQC has said that the only time that magazines would be an issue ‘would be if we found they were being used in such a way as to compromise the safety of someone using the service – and it's pretty hard to see what those circumstances might be'.
MYTH 6: The CQC will try to close us down if we don’t comply with all the national standards at inspection
If your practice is not compliant with the regulations, the response will depend on whether the impact on service-users is considered minor, moderate or major.
In most cases, it will require the practice to address failures within a reasonable agreed timeframe.
The CQC will only take enforcement action if this does not happen or the failure is judged to be sufficiently serious. It will not adopt a 'one size fits all' approach and will ‘tailor our judgments and expectations to your specific type and size of service.’
For example, it will only take action if patients are being put at risk because of unsafe premises and not simply because they are not state-of-the-art premises.
- Dr Old is a medico-legal adviser at the MDU, www.the-mdu.com